Title
Mecano vs. Commission on Audit
Case
G.R. No. 103982
Decision Date
Dec 11, 1992
NBI director seeks reimbursement for medical expenses; SC rules Administrative Code of 1987 did not repeal Section 699 RAC, granting his claim.
A

Case Summary (G.R. No. 103982)

Petitioner

Mecano incurred medical and hospitalization expenses during hospitalization from March 26, 1990 to April 7, 1990. He sought reimbursement under Section 699 RAC (as amended by R.A. No. 1232) through administrative channels, ultimately pursuing judicial relief by certiorari to annul COA’s denial.

Respondent

COA denied the claim on the ground that Section 699 of the RAC had been repealed by the Administrative Code of 1987 (Executive Order No. 292) because Section 699 was not restated in the 1987 Code. COA suggested filing with the Employees’ Compensation Commission as the illness occurred after the effectivity of the 1987 Administrative Code.

Key Dates

  • Hospitalization: March 26–April 7, 1990.
  • Petition for reimbursement memorandum to NBI Director: May 11, 1990.
  • NBI 1st Indorsement to Secretary of Justice: June 22, 1990.
  • COA Chairman 5th Indorsement: September 19, 1990.
  • Undersecretary Bello 4th Indorsement returning claim: November 21, 1990.
  • Opinion No. 73 (Secretary Drilon): April 26, 1991.
  • Director Lim 5th Indorsement resubmitting claim: May 10, 1991.
  • Secretary Drilon 6th Indorsement forwarding to COA Chairman: July 2, 1991.
  • COA 7th Indorsement denying claim: January 16, 1992.
  • Undersecretary Montenegro 9th Indorsement advising elevation to Supreme Court: February 7, 1992.
  • Supreme Court decision: December 11, 1992.

Applicable Law

  • Section 699, Revised Administrative Code of 1917 (as amended by R.A. No. 1232, June 7, 1955) — allowances for injury, death or sickness incurred in performance of duty and payment of necessary hospital fees where sickness is caused by or connected directly with performance of duty.
  • Administrative Code of 1987 (Executive Order No. 292), particularly Section 27, Book VII (Final Provisions) — general repealing clause: “All laws, decrees, orders, rules and regulations, or portions thereof, inconsistent with this Code are hereby repealed or modified accordingly.”
  • Employees’ Compensation Program under P.D. 626 and Article 173, Book IV of the Labor Code as amended by P.D. 1921 (second sentence quoted in the decision clarifying non-bar to Section 699 recovery).
  • Governing constitutional framework: 1987 Philippine Constitution.

Issue Presented

Whether the Administrative Code of 1987 repealed or abrogated Section 699 of the Revised Administrative Code, thereby precluding petitioner’s claim for reimbursement, and whether recovery under Section 699 is barred by the Employees’ Compensation scheme.

Relevant Facts and Administrative Processing

Mecano submitted his reimbursement claim through NBI administrative channels. The NBI recommended favorable action; the DOJ Committee on Physical Examination found the illness service-connected. Undersecretary Bello initially returned the claim following COA’s September 19, 1990 indorsement that the RAC provision relied upon had been repealed by the 1987 Administrative Code. Secretary Drilon issued Opinion No. 73 (April 26, 1991) that the issuance of the Administrative Code did not operate to repeal or abrogate in its entirety the Revised Administrative Code, including Section 699. Secretary Drilon forwarded the claim to COA for payment recommendation, but COA’s Chairman denied it on the ground of repeal by implication because Section 699 was not restated in the 1987 Code.

COA’s Position

COA maintained that the Administrative Code of 1987 superseded the RAC in its entirety. COA relied on the 1987 Code’s whereas clauses and the general intent to create a unified Administrative Code, arguing that omission of Section 699 from the 1987 Code meant its repeal. COA also contended that employment-related sickness, injury or death is adequately addressed by the Employees’ Compensation Program, and allowing concurrent recovery would be unjust to the government.

Petitioner’s Position

Petitioner relied on Section 699 of the RAC (as amended) and Secretary Drilon’s Opinion No. 73 that the Administrative Code of 1987 did not abrogate Section 699 in its entirety. Petitioner further argued that filing with the Employees’ Compensation Commission would not bar recovery under Section 699.

Legal Principles on Repeal and Statutory Construction Applied by the Court

  • Repeal is a matter of legislative intent; express repeal occurs when a statute specifically identifies the prior law revoked; other repeals are by implication.
  • A general repealing clause (such as Section 27 of the 1987 Code) that does not specifically identify prior laws operates conditionally: it repeals only insofar as there is an irreconcilable inconsistency between the new and prior law. The failure to include specific repealing language indicates lack of intent to repeal unless the new law and the old are repugnant.
  • Two forms of implied repeal: (1) irreconcilable conflict where the two statutes cannot be harmonized; (2) the later act covers the whole subject matter and is clearly intended as a substitute. Repeal by implication is not favored; the intent to repeal must be clear and manifest. Laws are presumed passed with knowledge of existing laws; harmonious construction is preferred where reasonably possible. The Court relied on authority and rules cited in the decision to articulate these principles.

Application of Legal Principles to the Two Administrative Codes

The Court compared the RAC and the Administrative Code of 1987 and found that the 1987 Code did not purport to cover the entire subject matter of the old Code. Several matters from the RAC were not restated in the 1987 Code, including notaries public, the leave law, public bonding law, military reservations, and claims for sickness benefits under Section 699. Because the subject provision (Section 699) was not restated, COA’s argument that omission equals repeal was rejected: omission alone does not demonstrate manifest legislative intent to abrogate prior provisions. The Court found no irreconcilable conflict between Section 699 and the 1987 Administrative Code; rather, the general repealing clause of the 1987 Code operates only to the extent of inconsistency. The 1987 Code was held not to be a complete substitute covering the whole subject matter of the RAC so as to effect repeal of omitted provisions.

Weight of Secretary of Justice Opinion and Review of Administrative Action

The Court recognized that Opinions o

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